Before appointing the managers1 of a financial institution, a non-objection from the Bank of Lithuania regarding the candidate for the future manager must be obtained. For this purpose, the candidate completes the questionnaire of a manager of a financial market participant supervised by the Bank of Lithuania (“Manager Questionnaire”) and submits it to the Bank of Lithuania for assessment. We would like to note that a new version of this questionnaire has been approved since March.
While representing clients in this process at the Bank of Lithuania, we have noticed several recurring mistakes. Therefore, we share 4 tips that will be useful for candidates when completing the Manager Questionnaire:
When completing the Manager Questionnaire, rely on official sources and databases: it is likely difficult to remember all your workplaces, periods of employment, and how long you worked at each. It is also understandable that there is no need to keep in memory which companies you participated in as a member of the board or supervisory council. The Bank of Lithuania verifies all information about the candidate using official sources or available databases. Therefore, we recommend retrieving your personal data from SODRA, the Register of Legal Entities, and Creditinfo before completing the questionnaire, and using this information when filling out the Manager Questionnaire.
Complete the questionnaire carefully and answer all parts of each question fully: if you are asked to indicate the name of your former employer, provide it exactly as registered in the Register of Legal Entities; make sure you indicate the correct legal entity code. In addition, do not skip any part of the question: for example, if you are asked to indicate the employer’s name, code, address, and a brief description of activities, do not omit any of these items, as you will be asked to supplement your answers. This may seem like a technical detail, but the candidate assessment process at the Bank of Lithuania will be extended by at least 2 weeks while waiting for you to submit the corrected questionnaire.
Disclose all administrative penalties imposed on you during the last 10 years: candidates often rush to select “No” when answering whether they have been subject to administrative penalties. Please note that fines for traffic violations also fall under this question and must be disclosed. We recommend obtaining a certificate from the Administrative Offences Register and completing the Manager Questionnaire based on that certificate, without omitting any administrative offences.
Provide additional explanations regarding facts indicated in the Manager Questionnaire that could raise additional questions for the Bank of Lithuania: for example, if you indicate that you have been fined 50 times for traffic violations over the past 10 years, supervisory authorities will very likely have concerns about the candidate’s reputation. Therefore, to address such concerns proactively, submit explanations together with the Manager Questionnaire regarding the number of penalties.
1 Typically, “manager” includes: the head of administration and their deputy, as well as members of the management board and supervisory council.
